2008-05-28_REVISION - C1981019 - Laserfiche WebLink

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achievable levels. To the contrary, goals and subsequent efforts will be designed to "strongly emphasize " and obtain greater acreages of shrub-dominated communities on a much greater portion of the reclaimed landscape. If Colowyo is successful in achieving the desired goals, there will be a component of "compensation" that will result. With regard to the use of strip-seeding ("banded seeding approach ") on grassland areas, the potential for use of this technique has been extended to 15% slopes (see response to Comment 416) at the discretion of the reclamation coordinator. With regard to the three bulleted items in this comment, Colowyo concurs with the third bulleted item that "a standard of at least 250 live woody plants per acre will apply on at least 3% of the pre- 2008 reclaimed surface ". With regard to the second bulleted item, Colowyo does not concur with the Division's suggestion, especially given that precedent has already been set in Northwest Colorado for the proposed zero woody plants on grassland targeted areas. Although, Colowyo continues to propose zero woody plants on grassland (grazingland land use) targeted areas as a success criterion, the proposed seed mix contains 42% shrub seed based on the total number of seeds to be planted. This fact indicates that the "goal " will be to achieve a substantial woody plant component in these areas, however, there should not be a success criterion for an area that is primarily intended as grazingland. With regard to the first bulleted item, it seems that the Division and/or CDOW has not fully considered Colowyo 's multi faceted approach to addressing the well-established difficulty of attaining elevated densities of shrubs within a short time span such as the 10 year bond responsibility period. This new approach has been carefully designed to provide a scientifically defensible procedure to document at the end of the bond responsibility period that shrub populations are on the path to provide adequate density after additional time and recruitment events have passed if they do not already exhibit adequate density to be releasable. This procedure allows for the variable densities that are often obtained (and are typical of native circumstances), as well as allowance for necessary additional time for populations to expand and achieve equilibrium densities (assuming they exhibit a positive recruitment rate). Despite the sound ecological principles and logic presented in this approach, Colowyo has proffered a compromise position and now offers within the revised text of Section 4.15.8, the following as a woody plant density standard for those areas achieving Sagebrush Steppe classification and originating from either areas targeting shrubland or grassland. "On manifested shrublands ... the following criteria will be applied depending on shrubland classification. On "core areas" (areas ofshrub concentration and comprising no less than one-third the total shrubland acreage), the eventual desirable goal shall be 1000 plants per acre, but the standard shall be 375 live plants per acre after 10 years, or 200 live plants per acre with documentation of a positive recruitment rate (within Colowyo reclaimed shrub communities). At least one-half of these totals shall be sagebrush species. Similarly, in "ecotonal areas " (comprising no more than two-thirds of the total acreage), the eventual desirable goal shall be 500 plants per acre, but the standard shall be 200 plants per acre after 10 years, or 100 plants per acre with documentation of a positive recruitment rate (within Colowyo reclaimed shrub communities). " The CDOW's desire to obtain greater shrub densities in lesser time, though laudatory, is somewhat naive given the present state-of-the-art of revegetation. It also does not take into consideration the habitats and habitat diversity that occurred in the American West prior to the influence of European man. Though certain techniques have been found to occasionally work elsewhere